Bristol-Myers Squibb: Frequently Asked Questions
 
Frequently Asked Questions

Q: What is Bristol-Myers Squibb’s policy on transparency?
A: Bristol-Myers Squibb supports the goal of providing transparency of the scope and nature of interactions between biopharmaceutical companies and organizations, including patient advocacy organizations that provide and purchase health care on behalf of the U.S. population. It is critical that health care decisions be based solely on what is best for patients - considering the best evidence that will enable the highest quality of health care delivery to optimize patient outcomes.

Q: What types of payments will Bristol-Myers Squibb disclose?
A: Bristol-Myers Squibb is disclosing payments made starting in January 2009 for independent medical education (IME) grants, charitable donations to community, patient and professional organizations, and other corporate giving, including sponsorships and corporate memberships. This includes payments made by a Bristol-Myers Squibb unit based in the United States or to a U.S.-based organization.

Q: Will Bristol-Myers Squibb disclose grants, charitable donations and other corporate giving outside the United States?
A: Bristol-Myers Squibb will disclose financial support for IME, charitable donations, and other corporate giving when funding is provided by a Bristol-Myers Squibb unit based in the United States or when funding is made to a U.S.-based organization by any Bristol-Myers Squibb unit.

Q: Why is Bristol-Myers Squibb choosing to disclose this information?
A: Bristol-Myers Squibb is proud to support the communities where our employees live and work. Among other important principles, our Company Commitment promises "conscientious citizenship that improves health and promotes sustainability in our communities." In line with our Mission and Commitment, we are proud to support independent medical education (IME) and community-based groups and programs (including patient organizations and medical societies) across the United States and around the world.

Q: Does Bristol-Myers Squibb disclose other types of information?
A: Bristol-Myers Squibb supports appropriate efforts to increase transparency into its relationships with health care professionals and complies with state reporting requirements regarding disclosure of advertising spend, gifts, grants and payments to health care professionals and others.

Additionally, Bristol-Myers Squibb discloses information regarding clinical trials, political contributions in the United States, support provided to patient groups in the United Kingdom and support of European patient groups. The Bristol-Myers Squibb Foundation, an independent 501(c)(3) organization, is subject to separate reporting requirements.

Q: What is the difference between an independent medical education grant, charitable donation and other corporate giving?
A: An independent medical education grant is made to support a specific activity designed to educate a health care provider (e.g., physician, pharmacist, nurse, nurse practitioner, physician’s assistant).

A charitable donation is made for the general support of an organization exempt from federal income tax under section 501(c)(3) of the Internal Revenue Code of 1986, as amended from time to time, or is exempt from federal income tax as a government entity.

Other corporate giving includes sponsorship of a specific activity of an organization, corporate memberships and support provided for fellowships and scholarships.

For additional information about each of these types of funding, please visit www.bms.com/medicalgrants or www.bms.com/communitygrants.

Q: What information is available in this report?
A: Bristol-Myers Squibb will, on a quarterly basis, disclose payments made in support of IME, charitable donations and other corporate giving. The report lists the name of the requester, co-requester (if applicable), request title, payment amount, and fund from which the payment was made.

Q: Does this report include payments made by the Bristol-Myers Squibb Foundation?
A: No. The Bristol-Myers Squibb Foundation, an independent 501(c)(3) organization, is subject to separate reporting requirements. Information regarding the Bristol-Myers Squibb Foundation is available at: http://www.bms.com/foundation/reducing_health_disparities/Pages/default.aspx

Q: What is a co-requester?
A: A co-requester is a separate organization identified by the requesting organization in its application submitted to BMS for financial support. A co-requester may be responsible for implementing an aspect of the activity in cooperation with or at the direction of the requesting organization.

Q: What does the fund column mean?
A: The fund column denotes whether a payment was made solely by Bristol-Myers Squibb or by Bristol-Myers Squibb on behalf of Bristol-Myers Squibb and an alliance partner. A payment may or may not be split equally between Bristol-Myers Squibb and the alliance partner.

Q. Why are negative payments listed?
A: A negative payment occurs when an organization returns unused grant funds to Bristol-Myers Squibb.

Q: Why are there multiple payments to the same organization with the same program title listed?
A: In some instances, Bristol-Myers Squibb makes multiple payments to the requesting organization over the term of the IME grant, charitable donation, sponsorship or corporate membership.

Q: Did Bristol-Myers Squibb notify grant applicants of its intention to disclose funding support?
A: Applicants to Bristol-Myers Squibb for IME, charitable donation, or other corporate giving with U.S.-based addresses that submitted a request through our online process from 2005 onward were notified of our disclosure plans in July 2008. Current applicants are informed of our right to disclose information about their funding request during our online application process.

Q: Why are you not disclosing funding support made before January 2009?
A: In the first quarter of 2008, Bristol-Myers Squibb made the decision to disclose funding beginning with requests approved on or after January 1, 2009. This decision allowed us to properly inform our requestors, align the disclosure decision with our alliance partners and develop the technical infrastructure necessary for disclosure.

Q: How can organizations apply to Bristol-Myers Squibb for funding?
A: Bristol-Myers Squibb accepts applications for funding for IME, charitable donations, and other corporate giving at: Bristol-Myers Squibb: Grants & Giving. The application for funding of community grants in New Jersey, Bucks County, Pennsylvania; Syracuse, New York; and Devens, Massachusetts is available at Bristol-Myers Squibb: Building our Communities

Q: How many requests for financial support does Bristol-Myers Squibb receive each year? Is the request volume consistent throughout the year?
A: Bristol-Myers Squibb receives several thousand requests for support of IME, charitable donations and other corporate giving each year. Based on past years, the volume is consistent throughout the calendar year.

Q: How does Bristol-Myers Squibb make funding decisions?
A: All applications for IME, charitable donations and other corporate giving are reviewed using objective criteria based on Bristol-Myers Squibb policy(ies)– and, where applicable, alliance partner policy(ies). Our policies are consistent with applicable laws and guidance documents, including the U.S. Food and Drug Administration guidance, the PhRMA Code on Interactions with Healthcare Professionals, the Department of Health and Human Services Office of the Investigator General Compliance Program Guidance for Pharmaceutical Manufacturers, the Federal Anti-Kickback Statute, the Foreign Corrupt Practices Act, and the Accreditation Council for Continuing Medical Education Standards for Commercial Support.

Q. How is the amount of the grant determined?
A: We consider several factors including the level of funding available and review of the budget submitted with the request to assure it is in accordance with established Bristol-Myers Squibb guidelines and policies.

Q: Does previous support guarantee future support?
A: No. Requests are reviewed on an individual basis as they are submitted.

Q: What could cause a request to be denied?
A: Bristol-Myers Squibb gives careful consideration to each application for IME, charitable donations or other corporate giving we receive, but unfortunately we are not able to support all requests. A request may be denied for several reasons, including, but not limited to:

  • the proposed IME activity is not aligned with Bristol-Myers Squibb’s current areas of medical interest
  • the request for a charitable donation or other corporate giving is not aligned with Bristol-Myers Squibb’s currently identified giving priorities
  • one or more similar requests have already been funded
  • lack of available funds
  • support of the request would conflict with Bristol-Myers Squibb policy

Q: How do you ensure that there are no conflicts of interest between Bristol-Myers Squibb and organizations that receive funding?
A: Bristol-Myers Squibb policy prohibits the involvement of Bristol-Myers Squibb employees in the design and/or implementation of independent medical education programs. Additionally, IME grants, charitable donations, and other corporate giving may not be tied, in any way, to past, present or future prescribing, purchasing, or recommending (including formulary recommendations) of any drug. Any evidence that suggests that a request is in violation of Bristol-Myers Squibb policy will be cause for rejection of the request. Violation of Bristol-Myers Squibb policy by a Bristol-Myers Squibb employee can result in disciplinary action, up to and including termination.

Q: Will public disclosure by Bristol-Myers Squibb affect my ability to receive support in the future?
A: No. Public disclosure will have no impact on the approval process for funding support. Each application is processed and reviewed according to Bristol-Myers Squibb policies.

Q: What does “Service Anniversary Donation” or “Retirement Donation” mean?
A: A Bristol-Myers Squibb employee celebrating a significant milestone in their employment with Bristol-Myers Squibb may opt to have the company make a donation to a 501c3 charitable organization in lieu of holding a celebration. These donations are noted as a Service Anniversary Donation or a Retirement Donation in the report.

Q: What does “Bereavement Donation” mean?
A: A Bristol-Myers Squibb employee may opt to have the company make a donation to a 501c3 charitable organization in lieu of flowers for bereavement of immediate family members. This type of donation is noted as a Bereavement Donation in the report.

What does “Holiday Celebration Donation” mean?
A: In lieu of holding a Holiday party, departments at Bristol-Myers Squibb may opt to make a donation to a 501c3 charitable organization. This type of donation is noted as “Holiday Celebration Donation” in the report.

 
 
 
 


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